The Federal Communications Commission (FCC, Commission) has released a Further Notice of Proposed Rulemaking and related Public Notice (FNRPM and PN) proposing new caller identity information requirements, foreign-origin call indicators, and removal of outdated robocall/TCPA rules. The comment dates have not been set and are pending until the item is published in the Federal Register.
In this FNPRM, the Commission proposes:
- requiring terminating voice service providers (VSPs) to communicate verified caller identity information to consumers’ handsets when signaling A-level SHAKEN attestation,
- requiring originating VSPs to verify caller identity data,
- requiring the use of Rich Call Data (RCD) for secure transmission of caller identity information,
- conditioning A-level STIR/SHAKEN attestation on caller identity information verification,
- identifying foreign-originated calls, and
- deleting outdated TCPA/call-blocking rules.
Two proposals that we want to highlight for our clients are:
- removing the STIR/SHAKEN exemption for providers who lack control of the network infrastructure necessary to implement STIR/SHAKEN, and
- prohibiting legitimate spoofing of NANP U.S. numbers for foreign-originated calls.
The FCC also mentioned that it plans to revisit Know-Your-Customer (KYC) requirements in a separate proceeding.
Background
In the document, the FCC reminds readers that the STIR/SHAKEN framework has reduced number spoofing by authenticating calling numbers on IP networks, but it does not tell consumers who is calling, legacy CNAM databases are often inaccurate and manipulable, and spam labels may be misleading to consumers.
Key proposals and questions
- Define caller identity information
- The Commission proposes to define “caller identity information” as the caller’s name, location, and “other information regarding the source or apparent source of a telephone call” (excluding the originating telephone number and billing information). In the FNPRM, the FCC mentions logos as an example of “other information.”
- The Commission is seeking comment on this suggested open definition.
- Present verified identity with A-level attestation: The FCC proposes to require terminating VSPs that choose to display A-level STIR/SHAKEN attestation to also present verified caller identity information (at least a verified name) on handsets to reduce consumer confusion and improve answer rates.
- FCC Seeking Comment On: Whether this would benefit consumers; whether marketplace solutions alone are sufficient; what minimum data should be mandatory (caller name?); how privacy choices (e.g., *67) should be honored; and what the implications are for handset capabilities, as well as accessibility and Telecommunications Relay Services (TRS) scenarios.
- Verify caller identity at call origination: The Commission proposes to require originating VSPs that transmit caller identity information to take reasonable measures to verify its accuracy, with comment sought on what “reasonable” entails, how to tailor by caller type/volume, and potential shared responsibilities with terminating providers; and enforcement backstops when the originating provider is a reseller or when the caller utilizes a branded calling solution provided by a third-party vendor.
- FCC Seeking Comment On: What data and vetting are necessary; how to regulate resellers, logos/brand authorization, family plans, and minor consumers; what practical, operational, or business challenges there may be; how to define “accurate” information; whether different rules should apply to different callers (e.g., based on call volume); what technical standards would be helpful; and whether a “trusted framework” should certify verified identity claims given evidence that many illegal calls carry A-level attestation.
- Secure transmission of identity data: The Commission seeks comment on requiring secure, end‑to‑end transmission of caller identity information and whether to mandate RCD standards (which sign identity in PASSporTs) or allow interoperable alternatives, including standard selection and maturity, as well as small-provider impacts.
- FCC Seeking Comment On: Whether RCD enables secure transmission of caller identity information; whether it should be required; how to ensure interoperability across IP/non‑IP segments; and what minimum requirements should apply if RCD is not mandated.
- Conditioning A-level STIR/SHAKEN attestation on Caller Identity Information verification: The Commission is considering conditioning A‑level attestation on verified caller identity instead of requiring originating providers to simply verify the accuracy of caller identity information; addressing “knowledge gaps” in reseller scenarios via certificate delegation, and other approaches to improve identity assurance. The Commission is also suggesting removing the STIR/SHAKEN exemption for providers who lack control of the network infrastructure necessary to implement STIR/SHAKEN so that the reseller that has the relationship with the caller has an obligation to authenticate calls using STIR/SHAKEN.
- FCC Seeking Comment On: Feasibility, effectiveness for deterring A-level attestations for spoofed calls, timelines, effects on analytics and consumer trust, and alignment with existing STIR/SHAKEN standards.
- Identifying foreign-originated calls: The FCC is proposing to require gateway providers to mark foreign-originated calls, intermediates to pass the indicator, and terminating VSPs to display a foreign-origin indicator to consumers, and to include foreign origin as a factor in required reasonable call analytics for call blocking.
- FCC Seeking Comment On: Feasibility; exemptions; how to determine and securely convey origin (e.g., OrigID/PASSporT), handset presentation, treatment of legitimate offshore operations and roaming, use of designated area codes, and lessons from the UK’s Ofcom’s approach to mitigating foreign spoofing (the Ofcom’s decision included a requirement to block all calls coming from abroad using a U.K. telephone number with certain exceptions).
- Prohibit spoofing of NANP U.S. phone numbers for foreign-origin calls: The FCC is seeking comment on prohibiting spoofing of U.S. NANP numbers on foreign-originated calls, including when the caller is otherwise authorized, and on the resulting impacts on consumers and offshore business operations.
- FCC Seeking Comment On: Comparative risk of harm, technical/standards implications, international coordination, and whether a foreign-origin indicator alone would suffice.
- FCC’s Proposals as Part of the DELETE! DELETE! DELETE! Proceeding:
Many of these proposals are designed to make business operations easier by loosening restrictions. However, for the consent revocation rule, the FCC is asking whether it should loosen, maintain, or make it more restrictive. We recommend that businesses take advantage of the opportunity to share their comments.
- Consent revocation rule: The FCC is asking whether to modify the requirement that a caller must treat an opt-out request made in response to one type of call to be an opt-out request for all types of calls (this rule’s implementation was delayed to April 11, 2026), or to modify it to give consumers greater control over their right to stop unwanted calls. Should the FCC permit callers to designate the exclusive means by which consumers may revoke prior express consent rather than requiring callers to honor all revocation requests made using “reasonable means”? How else should the consent revocation rule be modified?
- Call abandonment limits: The FCC is asking whether to delete the FCC rules on 15‑second/four‑ring and 3% abandonment rules given evolved dialers, overlap with the FTC’s Telemarketing Sales Rule (which applies to only interstate calls), and risk of consumer harm versus compliance burdens.
- Artificial/prerecorded caller ID callback: The FCC is asking whether to eliminate the requirement to provide a telephone number other than a 900 number or any other number for which charges exceed local or long distance transmission charges to reflect today’s charges and instead require that callers identify themselves with their telephone number to enable called consumers to know who is calling.
- Fraud alert calls: The FCC is asking whether to relax the limitation on financial institutions that fraud alerts may go only to the number provided by the consumer to improve reach for critical account security notices.
- Call blocking rules’ clean-up: The FCC is asking whether to eliminate permissive blocking rules for invalid/unallocated/unused or DNO-listed calls that have been superseded by equivalent obligations.
Public Notice on old TCPA filings
The FCC plans to dismiss with prejudice a list of thirteen (13) older TCPA-related petitions and applications absent an objection. The Public Notice lists affected filings from 2012–2021 and invites brief objections stating reasons to avoid dismissal.
Comment timing and filing
Comments are due 30 days after Federal Register publication; replies are due 60 days after publication; responses to the Public Notice are due 45 days after publication.
Conclusion
This FCC’s newest robocall mitigation rulemaking, positioned as the “First Major Step in Fresh Approach To Combatting Illegal Robocalls,” arrives alongside FCC’s anti-robocall enforcement and the Senate’s Foreign Robocall Elimination Act bill, which would introduce a bond requirement of up to $100,000 for companies to register in the Robocall Mitigation Database to impose costs upon “fraudulent providers.”
All interested stakeholders should consider filing comments, particularly if verified‑identity requirements, reseller obligations, foreign‑origin indicators, or restrictions on spoofing U.S. numbers for foreign calls could materially affect existing legitimate business models, including reseller arrangements or caller ID spoofing practices for lawful use cases. Our team can help with issue spotting, drafting, and strategic engagement on this proceeding and related compliance planning, including timing strategies around Federal Register publication and any shutdown‑related deadline adjustments.
WE CAN HELP MAKE YOUR VOICE BE HEARD!
The CommLaw Group’s wealth of specialized telecommunications law expertise, “inside the beltway” location, ability to see strategic implications of proposed rulemaking, and advocacy experience enable our clients’ voices to be heard! If you have any questions on this new development or would like assistance filing comments to the Further Notice of Proposed Rulemaking.
CONTACT US NOW!
Jonathan S. Marashlian – Tel: 703-714-1313 / E-mail: jsm@CommLawGroup.com
Michael Donahue — Tel: 703-714-1319 / E-mail: mpd@CommLawGroup.com
Susan Duarte – Tel: 703-714-1318 / E-mail: sfd@commlawgroup.com
Rob Jackson – Tel: 703-714-1316 / E-mail: rhj@CommLawGroup.com
Ron Quirk – Tel: 703-714-1305 / E-mail: req@CommLawGroup.com
Diana James – Tel: 703 663-6757 / E-mail: daj@CommLawGroup.com